guidance for quantifying and using long duration truck ... · 1/1/2004 · idling emissions cannot...

Office of Transportationand Air Quality

EPA420-B-04-001January 2004

Guidance for Quantifying andUsing Long Duration TruckIdling Emission Reductions inState Implementation Plans andTransportation Conformity

Printed on Recycled Paper

EPA420-B-04-001January 2004

Guidance for Quantifying and UsingLong Duration Truck Idling EmissionReductions in State Implementation

Plans and Transportation Conformity

Transportation and Regional Programs DivisionOffice of Transportation and Air Quality

and

Air Quality Strategies and Standards DivisionOffice of Air Quality Planning and Standards

U.S. Environmental Protection Agency

TABLE OF CONTENTS

Page

Section A: Background Information

1. What is the purpose of this guidance? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12. How does this guidance relate to existing Clean Air Act (CAA) requirements? . . . . 13. What are long duration truck idling emissions? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24. What is an idle reduction technology? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25. What are the benefits from using technologies to reduce long duration truck idling emissions? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

Section B: Basic Criteria Requirements for Long Duration Truck Idling Emissions Reductions

6. What are the basic criteria requirements for using emission reductions in SIPs or transportation conformity? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

7. What should you consider when implementing an idle reduction control measure? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Section C: Specific Considerations for Using Long Duration Truck Idling Emission Reductions

8. What are the total long duration truck idling emissions included in the SIP's emissions inventory or the regional conformity analysis? . . . . . . . . . . . . . . . . . 7

9. How can the estimated emission reductions be used for SIP purposes? . . . . . . . . . . . 810. How can the emission reductions be used for transportation conformity purposes? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

Section D: Quantifying Long Duration Truck Idling Emission Reductions

11. How do you quantify emission reductions from the use of an idle reductiontechnology? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

12. How do you quantify emission reductions for other criteria air pollutants orprecursors? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

Section E: Monitoring and Penalties

13. What monitoring and record keeping should occur to document long duration truck idling emission reductions? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

14. What validation and reconciliation should occur for emission reductions in SIPs approved under the Voluntary Measures Policy? . . . . . . . . . . . . . . . . . . . . . 15

15. What types of penalties can be assessed for not complying with CAA requirements? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

Section F: The SIP Process for Using Long Duration Truck Idling Emission Reductions

16. What must a state submit to EPA to meet the requirements for incorporating a source specific control measure in a SIP? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

Section G: Contact Information

17. Who should you contact for additional information? . . . . . . . . . . . . . . . . . . . . . . . . 16

Appendix A: Definitions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

Appendix B: NOx Emission Factors for Long Duration Idling Heavy Duty Diesel Vehicles . . 19

Appendix C: PM Emission Factors for Long Duration Idling Heavy Duty Diesel Vehicles . . 20

Appendix D: Quantification Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

Appendix E: Example Quantification (Mobile Idle Reduction Technology) . . . . . . . . . . . . . . 24

Appendix F: Example Quantification (Stationary Idle Reduction Technology) . . . . . . . . . . . . 27

LIST OF ABBREVIATIONS

AC Air ConditioningAPU Auxiliary Power UnitCAA Clean Air ActDOT Department of TransportationECM Engine Control ModuleGPS Global Positioning Systemg/bhp-hr Grams per brake horsepower hourg/kW-hr Grams per kilowatt hourg/hr Grams per hourg/mile Grams per milehp Horsepowerhr Hourlbs PoundsNOx Nitrogen OxidesPM Particulate Matter (2.5 and 10)RFP Reasonable Further ProgressROP Rate of ProgressRPM Revolutions Per MinuteSIP State Implementation PlanTIP Transportation Improvement ProgramTIUS Truck Inventory and Use SurveyTSE Truck Stop Electrification

1 Class 8 trucks are vehicles weighing over 33,001 pounds.

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Guidance for Quantifying and Using Long Duration Truck Idling Emission Reductions

(Note: As used in this document, the terms "we", "us" and "our" refer to EPA. The terms "you"and "your" refer to a state air pollution control agency or state or local transportation agency.)

Section A: Background Information

1. What is the purpose of this guidance?

The purpose of this document is to provide you with guidance on quantifying emissionreductions from technologies which reduce long duration truck idling emissions from Class 8trucks included in the state's on-road mobile sources inventory.1 This guidance is not intended toapply to emission reductions resulting entirely from state or local anti-idling laws, regulations, orordinances that limit a vehicle's idling time. You may wish to use the emission reductionsresulting from implementing an idling reduction technology for meeting emission reductionrequirements such as an RFP/ROP, attainment or maintenance SIP, or transportation conformitydetermination. Guidance on using these emission reductions for New Source Review offsetpurposes is addressed in a separate document.

2. How does this guidance relate to existing Clean Air Act (CAA) requirements?

This document provides guidance to state air pollution control agencies, transportationagencies, and the general public on how control measures to reduce truck idling emissions maybe used to meet SIP requirements. SIP requirements can be found in Sections 110(a)(2) and172(c) of the CAA, and transportation conformity requirements can be found in Section 176(c) ofthe CAA. This document does not substitute for those provisions, nor is it a regulation itself. Unless otherwise indicated, it does not impose binding, enforceable requirements on any party.Further, it does not assure that EPA may approve all instances of its application, and thus theguidance may not apply to a particular situation based upon the circumstances. The EPA andstate decision makers retain the discretion to adopt approaches on a case-by-case basis that differfrom this guidance where appropriate. Any decisions by EPA regarding a particular SIPdemonstration will only be made based on the statute and applicable regulations, and will only bemade following notice and opportunity for public review and comment. Therefore, interestedparties are free to raise questions and objections about the appropriateness of the application ofthis guidance to a particular situation; EPA will, and states should, consider whether or not therecommendations in this guidance are appropriate in that situation. This guidance is a livingdocument and may be revised periodically without public notice. The EPA welcomes publiccomments on this document at any time and will consider those comments in any future revisionsof this guidance document.

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Readers of this document are cautioned not to regard statements recommending the use ofcertain procedures as either precluding other procedures or information or providing guaranteesthat using these procedures will result in actions that are fully approvable. As noted above, EPAcannot assure that actions based upon this guidance will be fully approvable in all instances, andall final actions may only be taken following notice and opportunity for public comment.

3. What are long duration truck idling emissions?

Long haul drivers will often rest for long duration periods in their sleeper compartment. In fact, the Department of Transportation (DOT) requires that a truck driver rest for at least 10hours for every 14 hours of driving. During this rest period, truck drivers will often idle theirengines to operate the air conditioning, heat, or on-board appliances such as a television ormicrowave. Truck drivers will also idle their engines to keep their engine and fuel warm in coldweather. Another reason for long duration idling occurs while a truck driver waits (for example,at a border crossing), or waits to load or unload their truck (for example, at a company loadingdock, distribution center, or port). For purposes of this guidance, long duration idling is theoperation of the truck's propulsion engine when not engaged in gear for a period greater than 15consecutive minutes, except when associated with routine stoppages due to traffic movement orcongestion.

4. What is an idle reduction technology?

An idle reduction technology consists of the use of an alternative energy source in lieu ofusing the main truck engine for the purpose of reducing long duration truck idling. Some ofthese technologies are mobile and attach onto the truck (mobile auxiliary power units (APUs)),and provide air conditioning, heat, and electrical power to operate auxiliaries such as amicrowave.

Another technology involves electrifying truck parking spaces (stationary truck stopelectrification (TSE)) with or without modifying the truck. In general, this involves power fromthe electrical grid providing energy to operate stationary equipment or on-board truck equipmentto provide cab heating, cooling, and other needs.

This guidance addresses emission reductions generated from both mobile and stationarytechnologies. The EPA maintains a list of commercially available truck idle reductiontechnologies on its web site at the following address: http://www.epa.gov/otaq/retrofit/idlingtech.htm. This list is for informational purposes only, isnot an endorsement or verification of any specific idle reduction technology, and is not intendedas a complete list of all available idle reduction technologies.

5. What are the benefits from using technologies to reduce long duration truck idlingemissions?

2 Based on data collected, almost all diesel PM is submicron in size. Therefore, webelieve it is reasonable to use the same idling emission factor for both PM2.5 and PM10.

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The primary purpose of this guidance is to quantify emission reductions in criteria airpollutants and their precursors. This guidance specifically addresses emission reductions of NOxand PM2.5 and PM10.

2 In addition, there are other important benefits associated with reductions inlong duration truck idling emissions including:

C Reductions in the emissions of toxic air pollutants such as formaldehyde, and tracemetals such as nickel.

C Reductions in emissions of carbon dioxide.C Reductions in fuel consumption, decreased maintenance costs, and longer engine lifewhich results in cost savings to the truck owner.

C Reductions in noise levels.C Decreased dependency on oil imports.

Local communities near truck stops, rest areas, and other areas where long duration idlingoccurs, some of which are comprised of low income and minority populations, may benefit fromthe reduced pollution and noise levels as will truck drivers and truck stop employees.

Section B: Basic Criteria Requirements for Long Duration Truck Idling EmissionsReductions

6. What are the basic criteria requirements for using emission reductions in SIPs ortransportation conformity?

In order to be approved as a measure which provides additional emission reductions in aSIP or transportation conformity determination, a control measure reducing long duration truckidling emissions cannot interfere with other requirements of the CAA, and would need to beconsistent with SIP attainment, maintenance, or RFP/ROP requirements. Specifically, thecontrol measure must provide emission reductions that meet the criteria requirements describedbelow. These requirements are found in the CAA section 110 provisions concerning SIPs.

(A) Quantifiable - The emission reductions from a control measure to reduce long duration truckidling emissions are quantifiable if they can be reliably and replicably measured. Emissionreductions must be calculated for the time period for which the reductions will be used. SectionD of this document provides you with a method for quantifying emission reductions. You canalso submit your own quantification protocol which we will review and make a decision as to theappropriateness of its use on a case-by-case basis.

(B) Surplus - Emission reductions are generally surplus and can be used as long as they are nototherwise relied on to meet other applicable air quality attainment and maintenance requirements. In the event that the measure to reduce long duration truck idling emissions are relied on by you

3 For a description of this policy consult the following web site:http://www.epa.gov/otaq/transp/traqvolm.htm.

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to meet such air quality related program requirements, they are no longer surplus and are notappropriate to be used for additional credit.

In addition, to be considered surplus for SIP purposes the emissions from long durationtruck idling must be a part of the SIP's emissions inventory. For transportation conformity, theemissions from long duration truck idling must be part of the regional emissions analysis for theconformity determination.

(C) Federally Enforceable - Depending on how the emission reductions are to be used, controlmeasures to reduce long duration truck idling emissions must be enforceable either: (1) througha SIP or SIP revision; (2) through a permit issued under a SIP approved permitting program; or(3) through a transportation conformity determination. Where the emission reductions are part ofa rule, regulation, or permit they are considered federally enforceable if they meet all of thefollowing requirements:

C They are independently verifiable.C Violations are defined, as appropriate.C You and EPA have the ability to enforce the measure if violations occur.C Those liable for violations can be identified.C Citizens have access to all the emissions-related information obtained from theresponsible party.

C Citizens can file suits against the responsible party for violations.C Violations are practicably enforceable in accordance with EPA guidance onpracticable enforceability.

C A complete schedule to implement and enforce the measure has been adopted by the implementing agency or agencies.

If a SIP revision is approved under EPA's Voluntary Measures Policy, the state isresponsible for assuring that the reductions credited in the SIP occur. The state would need tomake an enforceable SIP commitment to monitor, assess and report on the emission reductionsresulting from the voluntary measure and to remedy any shortfalls from forecasted emissionreductions in a timely manner. Further, the total of all voluntary measures (including the idleemission reduction measures) may not exceed 3 percent of the total reductions needed to meetany requirements for RFP/ROP, attainment or maintenance as described under the policy. In thecircumstance where the actual emission reductions achieved are more than the amount estimatedin the SIP, you may take credit for the additional emission reductions provided it does not exceedthe 3 percent cap on voluntary measures and meets the other provisions of the VoluntaryMeasures Policy. If you wish to have a SIP revision approved under the Voluntary MeasuresPolicy consult that policy for further information.3

4 The historic idling activity should be used to estimate the idling emission reductions tobe achieved from the use of an idle reduction technology. This estimate should be comparedwith the actual emission reductions achieved after the monitoring period, as discussed in SectionE.

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(D) Permanent - The emission reduction must be permanent for the term that the emissionreduction is used.

(E) Adequately Supported - The state must demonstrate that it has adequate funding, personnel,and other resources to implement the control measure on schedule.

7. What should you consider when implementing an idle reduction control measure?

(A) Use a commercially available idle reduction technology which provides cab comfort needs(such as heat or air conditioning), and/or reduces idling during the truck driver's long durationrest or wait period, in lieu of idling the main truck engine;

(B) Use an idle reduction technology that is equipped with a non-resettable meter, data logger, orcomputerized data acquisition system capable of measuring total hours it operated;

(C) Comply with all necessary monitoring and recordkeeping reporting, validation, andreconciliation requirements as described in Section E of this guidance.

(D) In the case of stationary idle reduction technologies:

(1) Ensure the technology is located in a nonattainment or maintenance area for thepollutant or precursor for which emission reductions are generated; and

(2) Prior to quantifying emission reductions, determine the historic idling activity foreach location that will be generating emission reductions.4 This information shouldinclude sufficient documentation, such as survey or direct observation methods todetermine the following information:

(a) Percentage of truck parking spaces used at the location throughout the year(for example, annual occupancy rate);

(b) Of the percentage in (a) above, the percentage of those trucks which idle for along duration (defined as 15 consecutive minutes or more at idle); and

(c)(1) Of the trucks in (b) above, the historic number of hours the trucks idled perday for an average summer weekday for the past year (if pursuing NOx emissionreductions in an ozone nonattainment/maintenance area); or

5 If dealing with large numbers of vehicles, you can use fleet idling averages to determinethe historic long duration idling activity as demonstrated by previously recorded engine controlmodule data on a representative sample of trucks that travel through the nonattainment ormaintenance area.

6 Methods other than GPS should provide a high degree of confidence that the truck did,in fact, reduce idling emissions in the nonattainment or maintenance area. Truck driver logstypically do not provide a high degree of confidence.

7 If dealing with large numbers of vehicles, you can use fleet idling averages to determinethe historic long duration idling activity as demonstrated by previously recorded engine controlmodule data on a representative sample of trucks that travel through the nonattainment ormaintenance area.

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(c)(2) Of the trucks in (b) above, the historic number of hours the trucks idled perday for an average annual weekday for the past year (if pursuing PM or NOxemission reductions in a PM nonattainment or maintenance area).5

(E) In the case of mobile idle reduction technologies:

(1) Ensure the truck is equipped with a global positioning system (GPS) or anothermethod that is capable of demonstrating that the truck is in the nonattainment ormaintenance area throughout the time frame during which the emission reduction isquantified6; and

(2) Prior to quantifying emission reductions, determine the historic idling activity foreach truck that will be generating emission reductions. This information should includesufficient documentation, such as data from an engine control module and GPS todetermine the following information:

(a) The historic number of hours the trucks idled per day for an average summerweekday for the past year (if pursuing NOx emission reductions in an ozonenonattainment/maintenance area); or

(b) The historic number of hours the trucks idled per day for an average annualweekday for the past year (if pursuing PM or NOx emission reductions in a PMnonattainment or maintenance area).7

(3) Prior to generating emission reductions, you should collect the following informationfor the mobile idle reduction technology only: the manufacturer and manufacture date ofthe idle reduction technology, its engine model, and average daily horsepower load for thetime period for which you will be generating emission reductions.

8 The 3.4 percent limit on the total amount of emission reduction that can be used onlyapplies where the on-road mobile source inventory is based on MOBILE6 estimates. In thosecircumstances where the inventory is based on the latest EPA-approved California Air ResourcesBoard's Vehicle Emission Inventory modeling system (EMFAC), we will work with you on acase-by-case basis to determine the appropriate amount.

9 It is important to note that the annual emission factors for PM in Appendix C rely onMOBILE6.2 which will include PM emissions factors. The EPA will officially releaseMOBILE6.2 for SIP and transportation conformity purposes in the near future.

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Section C: Specific Considerations for Using Long Duration Truck Idling EmissionReductions

8. What are the total long duration truck idling emissions included in the SIP's emissionsinventory or the regional conformity analysis?

Some fraction of long duration truck idling emissions are included in emissioninventories based on MOBILE6 estimates through the model's use of conversion factors, butthese emissions are not a distinct and separate category. In particular, MOBILE6 uses conversionfactors to convert from g/bhp-hr to g/mile. The conversion factors were determined based onfactors including fuel economy estimates. These fuel economy estimates came from the U.S.Census Bureau's 1992 Truck Inventory and Use Survey (TIUS) study. Many of the TIUSrespondents reported fuel economy as long-term average fuel use per mile traveled, includingfuel used during long duration truck idling. The incorporation of these numbers in the g/bhp-hrto g/mile conversion factors means that some fraction of long duration idling activity is includedin the g/mile emissions factors produced by MOBILE6.

After reviewing the impact of fuel consumption on the conversion factor for Class 8trucks and the impact of the conversion factor on the g/mile emission factors for Class 8 trucksproduced by MOBILE6, we believe long duration truck idling emissions account for not morethan 3.4 percent of the total emissions for Class 8 trucks for any criteria pollutant or precursor inMOBILE6. Consequently, the total annual or average daily emissions reductions for all longduration idling controls in a nonattainment or maintenance area in any year is limited to anamount not to exceed 3.4 percent of the total annual or average daily Class 8 truck emissions forthat year.8

To quantify the total allowable emission reductions, for use in the on-road mobile sourceinventory, you should first determine the total emissions from heavy duty diesel Class 8 trucks inthe MOBILE6 emissions inventory or conformity analysis for the year in question and multiplythat value by 0.034 (3.4 percent). For example, the total allowable emission reductions for NOxin 2010 would be 3.4 percent of the Class 8 truck NOx inventory for 2010. Likewise, the totalallowable emission reductions for PM2.5 and PM10 in 2010 would be 3.4 percent of the Class 8truck PM2.5 and PM10 inventory for 2010.9 MOBILE6 projects a decrease in emissions fromheavy duty diesel Class 8 trucks in future years. Consequently, the total reductions a

10 For both mobile and stationary idle reduction technologies, determining the historicidling hours forms the basis for estimating the potential emission reductions. Differencesbetween the historic idling hours and estimated or actual idling hours may occur due to, forexample, warmer or colder temperatures than the historic time period.

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nonattainment or maintenance area can claim from all strategies to reduce long duration truckidling emissions, regardless of whether they are used for SIPs or transportation conformity, willalso decrease in future years.

The MOVES model, currently under development and intended to replace MOBILE6,will address long duration truck idling separately from other truck emissions and will correct anydiscrepancies in the actual long duration truck idling inventory. When we approve the MOVESmodel, you can use the long duration idling inventory number provided by that model. Until thattime, if you rely on MOBILE6 you should use the 3.4 percent limit.

9. How can the estimated emission reductions be used for SIP purposes?

For your SIP RFP/ROP, attainment or maintenance strategy, you can use the emissionreductions which are, or expected to be, generated from the idling reduction technology byapplying the following criteria:

(A) Based on the historic idling hours as determined in question 7(D)(2) and 7(E)(2)above, the estimated and actual emission reductions per day from the idle reductionproject should be a percentage of the historic idling hours per day. In the circumstancewhere the estimated or actual hours idled exceeds the historic idling hours, you shouldprovide an explanation as to the reason for the difference if you decide to seek credit forthe additional amount (that is, the actual amount). We will evaluate the reason for thedifference and make a decision as to the quantity of the emission reduction available on acase-by-case basis.10

(B) Where required, emission reductions must account for seasonality. For example, ifyour SIP only credits those reductions which take place during the summer ozone season,then only reductions in idling emissions which take place during that season may becredited.

(C) The total emission reductions from all controls on long duration truck idling for eachcriteria pollutant or precursor should not to exceed 3.4 percent of the Class 8 truck SIPemissions inventory for a given year when using MOBILE6 or MOBILE6.2 (see footnote9 for California exception).

10. How can the emission reductions be used for transportation conformity purposes?

The transportation conformity regulation (40 CFR parts 51 and 93) describes therequirements for including emission reductions from on-road mobile control measures in a

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conformity determination for a transportation plan, transportation improvement program (TIP),or transportation project. The conformity rule requires a regional emissions analysis beconducted for all non-exempt projects included in the transportation plan and TIP. In theregional emissions analysis, the emissions from future transportation activities are estimated ormodeled, just as they are when creating or revising a SIP's motor vehicle emissions inventory (or"motor vehicle emissions budget"). If credit is obtained for an idle reduction project in the SIP'sbudget, this does not preclude it from also being used towards the transportation conformitydetermination.

To include NOx or PM emission reductions from a truck idling control measure in aregional conformity analysis, the appropriate jurisdictions must be committed to the measure. The appropriate level of commitment varies according to the requirements outlined in 40 CFR93.122(a) which are described as follows:

(A) If the measure does not require a regulatory action to be implemented, it can beincluded in a conformity determination if it is included in the transportation plan and TIPwith sufficient funding and other resources for its full implementation.

(B) If the measure requires a regulatory action to be implemented, it can be included in aconformity determination if one of the following has occurred:

(1) The regulatory action for the measure is already adopted by the enforcingjurisdiction (e.g., a state has adopted a rule to require a control measure);

(2) The measure has been included in an approved SIP; or

(3) There is a written commitment to implement the measure in a submitted SIPwith a motor vehicle emissions budget that we have found adequate.

(C) If the measure is not included in the transportation plan and TIP or the SIP, and itdoes not require a regulatory action to be implemented, then it can be included in theconformity determination's regional emissions analysis if the conformity determinationcontains a written commitment from the appropriate entities to implement the measure.

Whatever the case, the emission reductions can only be applied in a conformitydetermination for the time period or years in which the truck idling control measure will beimplemented. Written commitments must come from the agency with the authority to implementthe measure. The latest emissions model and planning assumptions must be used whencalculating emission reductions from the measure, according to 40 CFR 93.110 and 93.111.

You should utilize the conformity interagency consultation process to discuss themethods and assumptions used to quantify the reductions from the measure. Section D of thisdocument provides you with a method for quantifying emission reductions. You can also submityour own quantification protocol which should include documentation of the methodology,

11 If dealing with large numbers of vehicles, you can use fleet idling averages todetermine the historic idling activity as demonstrated by previously recorded engine controlmodule data on a representative sample of trucks that travel through the nonattainment ormaintenance area.

12 As stated above, where the inventory is based on the latest approved CaliforniaEMFAC model, we will work with you on a case-by-case basis to determine the appropriateemission factors.

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assumptions, and models that were used to calculate emission reductions from long durationtruck idling measures, as well any commitments that are necessary to implement the project, asdescribed above. The conformity determination should also document that the total emissionreductions from all controls on long duration truck idling for a given pollutant or precursor is notto exceed 3.4 percent of the Class 8 truck emissions in the regional conformity analysis for agiven year when using MOBILE6 or MOBILE6.2 (see footnote 9 for California exception).

Section D: Quantifying Long Duration Truck Idling Emission Reductions

The following steps describe how to estimate the emission reductions from a proposedidle reduction project. In addition, these same steps can be used to determine the actual emissionreductions achieved from the project. Step 1 establishes the historic idling activity from whichyou will estimate an emission reduction. Steps 2 and 3 describe how to estimate the truckemissions that are reduced when using an idle control technology. Step 4 describes how toestimate the emissions associated with the idle reduction technology (this step is usually notnecessary if using a stationary idle reduction technology). Steps 5 and 6 describe how to estimatethe net reduction in emissions for the entire project. Finally, Steps 7 and 8 describe how todetermine how much of the net reduction is creditable in a SIP or transportation conformitydetermination. Appendix D provides a summary of Steps 1-6. Appendices E and F providequantification examples for mobile and stationary technologies.

11. How do you quantify emission reductions from the use of an idle reduction technology?

Step 1: Determine the historic idling activity of the trucks involved in the project.

For each truck using a mobile idle reduction technology, determine the historic idlinghours as described in question 7(E)(2). Likewise, for each parking space which will have astationary idle reduction technology installed, determine the historic idling hours as described inquestion 7(D)(2).11

Step 2: Select the emission factor for the criteria air pollutant or precursor.

In Appendix B and C, we provide emission factors for NOx and PM.12 These emissionfactors represent average emissions from a long duration idling truck. For NOx emissions, the

13 To the extent that there may be a concern that the power plant emission increasesresulting from a TSE project are not otherwise reflected in the state's overall consideration ofpower plant emissions, then the power plant increases in the nonattainment/maintenance areafrom a TSE project, where quantifiable, should be considered when quantifying the amount ofemission reductions.

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emission factor is 135 g/hr. For PM emissions, the emission factor will range from 0.33 g/hr to3.68 g/hr depending on the year in which the emission reduction is generated. Consult AppendixB and C for a full explanation of the basis for the emission factors. In the future, we may updatethe emission factors or include other criteria air pollutants or precursors.

Step 3: Multiply the emission factor in Step 2 by the number of hours per day the idle reductiontechnology is estimated to be used.

Estimate the average number of hours per day of idling emissions to be eliminated by theuse of the idle reduction technology. The estimated hours should be a percentage of the historicidling activity as determined in Step 1. In the case of mobile technologies, estimate the numberof hours that the technology will reduce long duration idling for each truck while in thenonattainment/maintenance area. For stationary technologies, estimate the number of hours thatthe technology will reduce long duration idling for each parking space. When determining theactual emission reductions from an existing project, using a mobile or stationary technology, usethe actual hours the technology was used.

When estimating the number of reduced hours of idling per day you need to consider theparticular pollutant or precursor and how the idling may vary by season or annually (for example,average summer weekday or average annual weekday) as described in question 7(D)(2) and7(E)(2).

Thus, to determine the emissions (g/day) from an individual truck prior to the use of anidle reduction technology use the following equation:

Emission Per Day = EFBASE * ALIRTWhere,

EFBASE = Truck baseline emission factor (NOx or PM in g/hr) (See Appendix B or C)

ALIRT = Estimated hours of use of idle reduction technology (hr/day)

Step 4(a): Determine emission factor for the mobile idle reduction technology.

In the case of stationary TSE, for the purpose of this guidance, it may be presumed that allemissions from power plants (including any increase in demand resulting from a TSE project)will be accounted for in projections of, or limits on, overall power plant emissions in the SIP'semission inventory. Therefore, related TSE emissions at power plants should not be consideredwhen quantifying the emission reductions associated with a TSE project.13

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If a TSE project does not rely on energy from the electrical grid, but instead is using analternative source of electricity (for example, a portable generator), then you should provide datathat demonstrates the emissions associated with that energy source. The data should comply withEPA regulations regarding the measurement of emissions from that energy source. If noregulations exist, provide all emissions data available to you for the energy source. We willreview this information and determine its appropriateness for use on a case-by-case basis.

You will now determine the emission factor associated with the mobile idle reductiontechnology used. If the mobile idle reduction technology is an EPA certified diesel fueled non-road engine, as is the case with many APUs, use the emission factor provided for that enginefamily by the manufacturer as part of its certification application under 40 CFR Part 89. Thisfactor is in g/kW-hr or g/bhp-hr and is publicly available (in Step 4(b) you will convert this factorto g/hr so the terms are consistent with Step 3). You should know the engine manufacturer'sname, year of manufacture, and 12-character EPA engine family number. This information isavailable on the engine label. You can obtain the emission data by contacting EPA's Office ofTransportation and Air Quality (Certification and Compliance Division) or consulting thecertification data at http://www.epa.gov/otaq/certdata.htm (search under "Non-RoadCompression Ignition Engine" and "Engine Family General Information" using the engine'smanufacture date).

Step 4(b): When using a mobile idle reduction technology, multiply emission factor from 4(a) bythe average daily horsepower load of the mobile idle reduction technology. Skip this step for astationary idle reduction technology.

Since the mobile idle reduction technology emission factor is usually in g/bhp-hr, youshould convert this emission factor to g/hr by multiplying by the average daily horsepower load. This step involves determining the average daily horsepower load which refers to the power useof the technology. This power use will differ during different times of the year depending onpower needs (AC or heat). For mobile auxiliary power units (including generator sets), theaverage daily horsepower load ranges from 4-8 hp. You should contact the idle reductiontechnology manufacturer (not the engine manufacturer) to determine the average dailyhorsepower load within this range for the time period considered. If the technology emissionfactor is in kW, you should convert this to horsepower by multiplying the kW by 1.34. Multiplying the emission factor by the daily horsepower load gives a gram per hour emissionfactor for the engine.

Step 4(c): When using a mobile idle reduction technology, multiply the g/hr factor by thenumber of operating hours (per day) it is estimated to be used. Skip this step for a stationaryidle reduction technology.

Thus, to determine the emissions (g/hr) for the idle reduction technology you shouldfollow the following equation:

Idle Reduction Technology Emission = EFIRT * HP * ALIRT

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Where,

EFIRT = Idle reduction technology emission factor (NOx or PM in g/bhp-hr)

HP = Average daily HP load

ALIRT = Estimated hours of use of idle reduction technology (hr/day)

Step 5: Determine the net emission reduction for the mobile technology. Skip this step for astationary idle reduction technology.

To determine the net emission reduction, subtract the emissions associated with the idlereduction technology as determined in Step 4 from the truck emissions as determined in Step 3. The equation is as follows:

NER = (EFBASE * ALIRT) - (EFIRT * HP * ALIRT)

Where,

NER = Net emission reductions in grams per day

EFBASE = Baseline emission factor (NOx or PM in g/hr)

ALIRT = Estimated hours of use of the idle reduction technology (hr/day)


HP = Average daily HP load


Net average daily emission reductions can be converted from grams to pounds bydividing by 454. If necessary for estimating annual reductions of NOx or PM, average dailyemissions reduced can be converted to annual emissions reduced by multiplying by the numberof days in the year it is assumed the technology will be used.

Step 6: Sum all emission reductions for the project.

For a truck stop electrification project, the sum would include the emission reductionsfrom the use of all the electrified parking spaces. For mobile technologies, the sum wouldinclude the emission reductions from all the participating trucks.

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Step 7: Make sure net average daily emissions reduced from the idling reduction project do notexceed the historic idling activity of the trucks involved in the project as determined in Step 1.

The daily emission reductions per day from the idle reduction project should be apercentage of the historic idling hours per day. In the circumstance where the actual hours idledexceeds the historic idling hours, you should provide an explanation as to the reason for thedifference if you seek credit for the additional reduction. We will evaluate the reason for thedifference and make a decision as to the quantity of the emission reduction available on a case-by-case basis. Where verified, the additional emission reduction may be credited.

Step 8: Make sure the net average daily emission reductions from all idling reduction projectsdo not exceed the total long duration idle emissions accounted for in the SIP's regional inventoryor regional conformity analysis.

The net average daily emission reductions for all existing and new long duration truckidling reduction projects in a nonattainment or maintenance area should be summed to determinethe total reductions from all programs for a given year. The total reductions claimed for allprograms should not exceed 3.4 percent of the emission estimate for Class 8 trucks for anycriteria air pollutant or precursor used in the applicable SIP inventory or conformity analysis forthe calendar year in question (see footnote 9 for California exception). See Section C for detaileddiscussion.

12. How do you quantify emission reductions for other criteria air pollutants or precursors?

To quantify emission reductions for other criteria air pollutants or precursors (such ashydrocarbon emissions), you can follow the same steps outlined in this section, substituting anEPA approved idling emission factor for that pollutant or precursor. Once we have identified anidling emissions factor for use, similar to those listed or referenced in this document, it maysubsequently be used in the same manner without additional review by us. If no idling emissionfactor has been identified, you can submit data supporting an idling emission factor and we willreview this data on a case-by-case basis and make a decision as to the appropriateness of its use.

Section E: Monitoring and Penalties

13. What monitoring and record keeping should occur to document long duration truck idlingemission reductions?

(A) For each truck or location generating emission reductions, the responsible partyshould monitor and record the following information for each time period for which an

14 The responsible party using a mobile idle reduction technology will likely be a truckfleet. For a stationary idle reduction technology, the responsible party will likely be the locationowner (or lessee) who owns and controls the technology.

15 Methods other than GPS should provide a high degree of confidence that the truck did,in fact, reduce idling emissions in the nonattainment or maintenance area. Truck driver logstypically do not provide a high degree of confidence.

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emission reduction is generated (or other information capable of demonstrating theemission reductions to our satisfaction).14

(1) For mobile and stationary technologies, the number of hours the idlereduction technology operated while the main truck engine did not idle, recordedby a non-resettable meter, data logger, or computerized data acquisition systemcapable of recording total hours operated on each truck.

(2) For mobile technologies only, GPS data or data from another method thatdemonstrates that the information recorded from (1) above occurred in thenonattainment or maintenance area.15

(B) All information to be monitored and recorded in accordance with this guidance forexisting SIP requirements should be maintained by the responsible party for a period ofno less than five years.

14. What validation and reconciliation should occur for emission reductions in SIPs approvedunder the Voluntary Measures Policy?

The SIP submission for a voluntary measure should contain a description of theevaluation procedures and time frame(s) in which the evaluation of SIP reductions will takeplace. Once the voluntary control measure is in place emission reductions should be evaluatedby you as required to validate the actual emission reductions. You should submit the results ofyour evaluation to EPA in accordance with the schedule contained in the SIP. If the reviewindicates that the actual emission reductions are not consistent with the estimated emissionreductions, then the amount of credit should be adjusted appropriately and applicable remedialmeasures should be taken under the Voluntary Measures Policy. See the EPA's VoluntaryMeasures Policy for further information regarding validation and reconciliation requirements forsuch measures.

15. What types of penalties can be assessed for not complying with CAA requirements?

Use of this guidance does not relieve the responsible party of any obligation to complywith all otherwise applicable CAA requirements, including those pertaining to the crediting ofemission reductions for your SIP, such as emission reductions for your attainment ormaintenance strategy. Violations of CAA requirements are subject to administrative, civil,and/or criminal enforcement under Section 113 of the CAA, as well as to citizen suits under

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Section 304 of the CAA. The full range of penalty and injunctive relief options would beavailable to the federal or state government (or citizens) bringing the enforcement action.

Section F: The SIP Process for Using Long Duration Truck Idling Emission Reductions

16. What must a state submit to EPA to meet the requirements for incorporating a sourcespecific control measure in a SIP?

You must submit to EPA a written document which:

(A) Identifies and describes the idle reduction project and its implementation schedule toreduce long duration truck idling emissions within a specific time period;

(B) Contains a quantification methodology to estimate the emission reductions from theidle reduction project. You can follow the quantification methodology provided inSection D of this document or you can submit your own. If you submit your ownquantification methodology for quantifying the emission reductions, you must provide allrelevant technical support documentation, including the information and quantificationuncertainties used to calculate emission reductions. You must rely on the most recentinformation available at the time the SIP is developed;

(C) Contains federally enforceable requirements for the responsible party (truck orlocation owner) to monitor and record the appropriate information;

(D) Under the Voluntary Measures Policy only, enforceably commits to evaluate andreport the resulting emission reductions of the measure as applicable;

(E) Enforceably commits to remedy any SIP emission shortfall in a timely manner if themeasure does not achieve estimated emission reductions; and

(F) Meets all other requirements for SIP revisions under sections 110 and 172 of theCAA.

Section G: Contact Information

17. Who should you contact for additional information?

State agencies, the regulated community and members of the public with questionsconcerning a case-specific application of this guidance should contact the EPA Regional Officewith responsibility for air quality planning in the area where the idle reduction project is located. A contact list of your EPA Regional Office is available at the following web address:http://www.epa.gov/epahome/locate2.htm

For general questions regarding the quantification of truck idling emissions reductions,please contact Paul Bubbosh of EPA's Office of Transportation and Air Quality at (202) 343-

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9322 or David Solomon of EPA's Office of Air Quality Planning and Standards at (919) 541-5375.

For general questions concerning the use of truck idling emissions reductions in SIP on-road mobile emissions inventories or in transportation conformity, please contact Meg Patulskiof EPA's Office of Transportation and Air Quality at (734) 214-4842.

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Appendix A

DEFINITIONS

For the purposes of this guidance only, the following definitions apply:

(A) ACTUAL IDLING EMISSION REDUCTIONS means the emission reductionsachieved from an idle reduction project.

(B) CLASS 8 TRUCK means a truck with a gross vehicle weight rating (GVWR) of33,001 pounds and over. GVWR is the weight of the truck and its payload, plus fuel anddriver.

(C) ESTIMATED IDLING EMISSION REDUCTIONS means the projected emissionreductions from an idle reduction project which is based on a percentage of the historicidling activity.

(D) GLOBAL POSITIONING SYSTEM means a satellite-based radio navigationreceiver capable of providing the time, date, and position of the truck.

(E) HISTORIC IDLING ACTIVITY means the demonstrated past long duration idling ofa Class 8 truck, or past long duration idling from Class 8 trucks at a particular location, inthe nonattainment or maintenance area.

(F) IDLE REDUCTION TECHNOLOGY means a commercially available technology ordevice that provides truck cab comfort needs, or otherwise reduces the need for long-duration truck idling.

(G) LONG DURATION IDLING means the operation of a truck's propulsion engine of aClass 8 truck for a period greater than 15 consecutive minutes at a time at which the maindrive engine is not engaged in gear (excluding routine stoppages due to traffic movementor congestion).

16 See the following reports: "Idle Emissions from Heavy-Duty Diesel and Natural GasVehicles at High Altitude," Robert McCormick, et al, Colorado Institute for Fuels and EngineResearch, Colorado School of Mines, Journal of the Air and Waste Management Association,Revised May 3, 2000; "Study of Exhaust Emissions from Idling Heavy-duty Diesel Trucks andCommercially Available Idle Reducing Devices," Han Lim, US EPA Office of Transportationand Air Quality, September 2002; "Preliminary Results for Stationary and On-Road Testing ofDiesel Trucks in Tulare, California," Douglas Lambert, et al, Clean Air Technologies Inc., May15, 2002; "NOx Emissions and Fuel Consumption of HDDVs during Extended Idle," David K.Irick, University of Tennessee, Bob Wilson, IdleAire Technologies Inc., Coordinated ResearchCouncil 12th Annual On-Road Vehicle Emission Workshop, San Diego, California, April 15-17,2002; "Heavy-duty Vehicle Chassis Dynamometer Testing for Emissions Inventory, Air QualityModeling, Source Apportionment and Air Toxics Emissions Inventory," Phase I Interim Report,CRC Project No. E-55/E-59, Mridul Gautam and Nigel N. Clark, et al, West Virginia UniversityResearch Corporation, July 2002; "Heavy-duty Vehicle Emissions," National CooperativeHighway Research Program Project 25-14, Cambridge Systematics, Inc., with Battelle, SierraResearch and West Virginia University. October 2002; "Internal Report - Idle Emissions fromHeavy-Duty Diesel Trucks in the New Your Metropolitan Area", Tang and Munn, New YorkState Dept of Environmental Conservation, November 9, 2001; "Potential Benefits of UtilizingFuel Cell Auxiliary Power Units in Lieu of Heavy-Duty Truck Engine Idling," Broderick, Dwyer,et al. Institute of Transportation Studies, University of California - Davis.

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Appendix B

NOx Emission Factors for Long Duration Idling Heavy Duty Diesel Vehicles

Year NOx Emission Factor (g/hr)

2002-2030 135

The emissions of trucks engaged in long duration idling vary due to factors such asengine manufacturer, age of vehicle, rpm at idle, and ambient temperature which influences theuse of auxiliaries such as air conditioning or heat. Based on an analysis of emission test data16,we have determined that, for NOx emissions, an emission rate of 135 grams per hour is areasonable average rate for long duration truck idling.

At this time, the impact of future NOx emissions standards on long duration idlingemissions is uncertain. Control measures, such as catalytic converters, intended to reducerunning emissions of diesel trucks in the future, may likely be less effective at controlling longduration idle emissions. As a result we have concluded that it is reasonable to use the emissionrate of 135 grams per hour for NOx for analyses of both current and future calendar years. Wewill review this assumption as emissions data on diesel trucks with more advanced controltechnology become available, and update these emission factors as appropriate.

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Appendix C

PM Emission Factors for Long Duration Idling Heavy Duty Diesel Vehicles

Table 1. For use in stationary truck stop electrification projects

Calendar Year PM2.5/PM10 Emission Factor (g/hr)

2006 and earlier 3.68

2007 3.43

2008 2.94

2009 2.52

2010 2.16

2011 1.88

2012 1.60

2013 1.38

2014 1.10

2015 0.89

2016 0.79

2017 0.71

2018 0.58

2019 0.54

2020 0.50

2021 0.47

2022 0.44

2023 0.41

2024 0.39

2025 0.38

2026 0.36

2027 0.35

2028 0.34

2029 0.33

2030 0.33

17 Storey, J., Thomas, J., et at., "Particulate Matter and Aldehyde Emissions From IdlingHeavy-Duty Diesel Trucks," Society of Automotive Engineers, Inc. Publication 2003-01-0289(2001); "Idle Emissions from Heavy-Duty Diesel and Natural Gas Vehicles at High Altitude,"Robert McCormick, et al, Colorado Institute for Fuels and Engine Research, Colorado School ofMines, Journal of the Air and Waste Management Association, Revised May 3, 2000; "NOxEmissions and Fuel Consumption of HDDVs during Extended Idle," David K. Irick, Universityof Tennessee, Bob Wilson, IdleAire Technologies Inc., Coordinated Research Council 12thAnnual On-Road Vehicle Emission Workshop, San Diego, California, April 15-17, 2002;"Heavy-duty Vehicle Chassis Dynamometer Testing for Emissions Inventory, Air QualityModeling, Source Apportionment and Air Toxics Emissions Inventory," Phase I Interim Report,CRC Project No. E-55/E-59, Mridul Gautam and Nigel N. Clark, et al, West Virginia UniversityResearch Corporation, July 2002.

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Table 2. For use in mobile idle reduction technology projects

Truck Model Year PM2.5/PM10 Emission Factor (g/hr)

2006 and earlier 3.68

2007 and later 0.33

Based on an analysis of emission test data17, we have determined that an emission rate of3.68 g/hr is a reasonable average total direct PM emission factor from long duration idling forindividual trucks prior to the 2007 model year and for truck fleets prior to the 2007 calendar year. Based on data collected, almost all diesel PM is submicron in size. Therefore, we believe it isreasonable to use this emission factor for both PM2.5 and PM10 calculations for 2002.

As in the case of NOx emissions, there is some uncertainty about the impact of future PMemissions standards on long duration idling. However, the control technologies used to controlrunning PM emissions are based on filters and traps which are more likely to show increasedeffectiveness under long duration idling conditions. Therefore, we expect long duration idlingemissions to decline in the future at a rate similar to the expected decline in running emissions. We will review this assumption as emissions data on diesel trucks when more advanced controltechnology become available, and update these emission factors as appropriate. In the meantime,emission factors from the previous tables should be used for a given year to estimate longduration idling PM2.5 and PM10 emissions from Class 8 vehicles.

Emission factors from Table 1 should be used in cases where stationary truck stopelectrification (TSE) is used as the long duration idle control measure. The emission factors inTable 1 are fleet average emission factors assuming fleet turnover to cleaner trucks beginning in2007. They are based on the assumption that the age mix of trucks using the truck stops will besimilar to the default age mix in MOBILE6.2. For a TSE project, choose the emission factor forthe calendar year of evaluation. For example, to estimate the benefits of a truck stopelectrification project in 2010, assume an emission factor of 2.16 g/hr for PM2.5 and PM10. Toestimate the benefits of a truck stop electrification project in 2020, assume an emission factor of0.50 g/hr for PM2.5 and PM10.

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Emission factors from Table 2 should be used in cases where mobile idle reductiontechnologies are used as the idle control measure. The emission factors in Table 2 are modelyear specific emission factors. For a mobile idle reduction project, choose the emission factor forthe model year of the vehicle that the mobile idle reduction technology is installed on. Forexample, to estimate the benefits of adding an APU to a 2002 model year truck, assume a longduration idling emission factor for the truck of 3.68 g/hr for PM2.5 and PM10. To estimate thebenefits of adding an APU to a 2010 model year truck, assume a long duration idling emissionfactor for the truck of 0.33 g/hr for PM2.5 and PM10. These same emission factors would be usedfor any calendar year of evaluation; that is, for estimating the benefits of a 2002 model year truckusing an APU in 2012, assume a long duration idling emission factor for the truck of 3.68 g/hrfor PM2.5 and PM10.

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Appendix D

Quantification Summary

The purpose of this quantification summary is to provide a concise formula to calculatethe net emission reduction for long duration truck idling. This summary is intended to beconsistent with the more detailed step-by-step process in Section D.

NER = (EFBASE * (ALIRT / CFG/LBS )) - (EFIRT * HP * (ALIRT / CFG/LBS))

Where,

NER = Net emission reduction

EFBASE = Truck baseline emission factor (NOx or PM in g/hr)


CFG/LBS = Conversion factor for grams to pounds which is 454


HP = Average daily horsepower load (ranges from 4-8 hp depending on thetechnology; contact the technology manufacturer)


There are three essential parts to this formula. First, you determine the emissions fromthe truck by selecting the emission factor for the pollutant or precursor for reduction, multiplythis factor by the number of hours you estimate the technology will reduce long duration idlingemissions. This number is divided by the conversion factor to derive a grams per hour number. The second part is to determine the emissions associated with the idle reduction technology (thisstep typically does not apply to stationary idle reduction technologies). This requires determiningthe emissions associated with the technology, multiplying this by the horsepower to derive agrams per hour number, multiplying this number by the number of hours the technology willoperate, and then dividing this number by the conversion factor. The final part is simplysubtracting the emissions from the second part (idle reduction technology emissions) by the firstpart (truck's baseline emissions) to arrive at the net emission reduction.

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Appendix E

Example Quantification

Mobile Idle Reduction Technology

This example is for the purpose of illustrating the quantification steps only, and it doesnot address the additional considerations to credit the reductions generated. In this example wewill estimate the NOx long duration idling emission reductions from idling Class 8 trucks using amobile idle reduction technology in 2007. In the nonattainment area, 100 vehicles will use thistechnology 7 hours per day. This is the only long duration truck idle reduction project in thenonattainment area. Total Class 8 truck NOx emissions projected for the nonattainment area in2007 are 80 tons per day.

For the idle reduction technology, we will use an auxiliary power unit (APU). The APUallows an idling truck to be shut down by providing air conditioning, heat, and electrical powerto operate auxiliaries such as a television and microwave.

Per the steps outlined in Section D of this document, the NOx emission reductionsassociated with the use of the APU is calculated as follows:

Step 1: Determine the historic idling activity of the truck involved in the project.

You should follow the discussion provided in question 7(E)(2) in this guidance to derivethe historic number of hours the trucks idled for an average summer weekday for the past year inthe nonattainment or maintenance area. In this example, we determined a truck's long durationidling occurred an average of 8 hours per day.


We are evaluating NOx emission reductions so the emission factor is 135 grams per hour.


We estimated that the APU will reduce 7 of the 8 hours of long duration idling. Therefore, the average daily emissions reduced is 135 grams/hr * 7 hours/day = 945 grams/day

Step 4(a): Determine emission factor for the mobile idle reduction technology.

18 For purposes of this example we have selected a specific engine model to betterillustrate the APU's emissions. The use of this engine model does not confer any endorsement ofthis company or its products.

19 In some circumstances, the NOx emission factor is reported as a combined NOx + HCemission factor. You will need to contact the engine manufacturer to determine the NOx onlyvalue.

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In this example, the APU uses a 2003 Kubota engine (EPA engine family3KBXL.719KCB)18 which was certified under 40 CFR Part 89. By examining the certificationdata for this engine family, we find the certified NOx emission level is 4.7 g/bhp-hr.19

Step 4(b): When using a mobile idle reduction technology, multiply emission factor from 4(a) bythe average daily horsepower load of the mobile idle reduction technology.

According to an APU manufacturer, the average daily horsepower load for this engineduring typical summer weekdays is 5 hp. The grams per hour emission rate of the auxiliarypower unit is 4.7 g/bhp-hr * 5 hp = 23.5 g/hr.

Step 4(c): When using a mobile idle reduction technology, multiply the g/hr factor by thenumber of operating hours (per day) it is estimated to be used.

As a result, the total average daily emissions of the APUs are 23.5 grams/hr * 7 hours/day= 164.5 grams/day.

Step 5: Determine the net emission reduction.

The estimated net emissions reductions from this program are 945 grams/day - 164.5grams/day = 780.5 grams/day or 1.72 lbs/day.


In this example, we estimate that all trucks will operate in a similar manner. In practice,each truck could have its own idling emission reductions. We add the total amount of idling forall 100 participating trucks in the project which is 100 * 780.5 = 78,050 grams/day or 171.9lbs/day.

Step 7: Make sure the net average daily emission reductions from the idling reduction projectdo not exceed the historic idling activity of the trucks involved in the project as determined inStep 1.

This step involves taking your estimate of idling activity (or the actual emission reduced)and reconciling this estimate (or actual number) with your historic idling hours from Step 1(following question 7(E)(2)). If the estimate (or actual number) exceeds the historic idling hours,you will need to explain this increase if you seek credit for the estimated (or actual) amount. Inthis example, the estimate does not exceed the historic idling activity.

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Step 8: Make sure the net average daily emission reductions from all idling reduction projectsdo not exceed the total long duration idle emissions accounted for in the regional inventory usedin the SIP or conformity determination.

In this example, total Class 8 truck NOx emissions projected using MOBILE6 for thenonattainment area in 2007 are 80 tons per day. The long duration idle portion of the 2007inventory for this area is assumed to be not more than 3.4 percent of 80 tons per day = 2.7 tonsper day. This is well over the estimated net reductions from this program of 171.9 pounds perday so full credit for the program can be taken, assuming all other requirements are met.

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Appendix F

Example Quantification

Stationary Idle Reduction Technology

This example is for the purpose of illustrating the quantification steps only, and it doesnot address the additional considerations necessary to credit the reductions generated. In thisexample we will estimate the long duration NOx idling emission reductions from an idling Class8 truck using truck stop electrification (TSE). In this example, 100 truck stop parking spaces areelectrified. On average these spaces (prior to electrification) are estimated to be used 10 hoursper day in 2007 based on historic idling activity. This is the only long duration idle reductionproject in the nonattainment area. Total Class 8 truck NOx emissions projected for the area in2007 are 80 tons per day.

Per the steps outlined in Section D of this document, the NOx emission reductions fromthese electrified truck stop spaces is calculated as follows:

Step 1: Determine the historic idling activity associated with the truck parking spaces involvedin the project.

You should follow the guidance provided in question 7(D)(2) above to derive the historicnumber of hours the trucks idled at the location for a typical summer weekday in thenonattainment area. For the purpose of this example, the estimated number of hours per day ofidling documented is 10.


We are evaluating NOx emission reductions so the emission factor is 135 grams per hour.


We estimate that the TSE will reduce 8 of the 10 hours idling. Therefore, the averagedaily emissions reduced is 135 grams/hr * 8 hours/day = 1,080 grams per day or 2.37 pounds perday.

Steps 4, 5: Determine emission factor for the mobile idle reduction technology; determine thenet emission reduction.

Since this example involves TSE, we presume that the electrical generation and emissionsmay slightly increase at local power plants and that all emissions from power plants (includingany increase in demand resulting form an electrification project) will be accounted for inprojections of, or limits on, overall power plant emissions in the state's attainment demonstration. Therefore, emission changes at power plants are not considered when quantifying the emissionreductions associated with the TSE project. Therefore, you can skip steps 4 and 5 for thisexample.

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In this example, we assume that all trucks will use each electrified space in a similarmanner. In practice, each electrified parking space could have its own idling emission reductionassessment. In this example, we add the total amount of idling for all participating trucks in 100parking spaces which is 100 * 1,080 = 108,000 grams/day or 238 pounds per day.

Step 7: Make sure the net average daily emission reductions from the idling reduction projectdo not exceed the historic idling activity of the trucks involved in the project as determined inStep 1.

This step involves taking your estimate of idling activity (or the actual emission reduced)and reconciling this estimate (or actual number) with your historic idling hours from Step 1(following question 7(D)(2)). If the estimate (or actual number) exceeds the historic idlinghours, you will need to explain this increase if you seek credit for the estimated (or actual)amount. In this example, the estimate does not exceed the historic idling activity.

Step 8: Make sure the net average daily emission reductions from all idling reduction projectsdo not exceed the total long duration idle emissions accounted for in the regional inventory usedin the SIP or conformity determination.

In this example, total Class 8 truck NOx emissions projected using MOBILE6 in 2007 are80 tons per day. The long duration idle portion of the 2007 inventory for this area is assumed tobe not more than 3.4 percent of 80 tons per day = 2.7 tons per day. This is well over theestimated net reductions from this program of 238 pounds per day so full credit for the programcan be taken.

NOTE: If both example projects as described in Appendix E and F were in place, the areawould for Step 8 compare the long duration idle emissions of the SIP inventory and/or regionalconformity analysis (in this case 2.7 tons per day) to the sum of the estimated emissionreductions from the two programs = 171.9 pounds per day + 238 pounds per day = 410 poundsper day assuming that the trucks with APUs always park in non-electrified spaces. Again, thecombined reductions from both programs is below 2.7 tons of NOx per day for the year 2007. Even if the estimated benefits from all programs to reduce long duration idling in this areaexceeded 2.7 tons per day, a maximum of 2.7 tons per day could only be claimed as credit in2007.

guidance for quantifying and using long duration truck ... · 1/1/2004 · idling emissions cannot...

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